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benefited from the 1991 interest payments. That inference would
lead this Court to conclude that petitioners are taxable on the
1991 interest payments. See supra sec. II.C.3.a.
In an attempt to rebut the inference that petitioner had
control over and benefited from the Yakima interest payments
portion of the 1991 interest payments, petitioners assert the
following: (1) on March 1, 1987, petitioner borrowed $200,000
from Mr. Bell, through Hansa Finance, and loaned those funds to
Chestnut Grove and Group M to make the initial downpayment on the
Yakima property; (2) on March 1, 1987, Chestnut Grove and Group M
executed notes to petitioner for $23,382 and $176,618,
respectively; (3) on March 1, 1988, petitioner borrowed $110,000
from Mr. Bell, through Hansa Finance, and loaned those funds to
Group M to make a second payment for the Yakima property; (4) on
March 1, 1988, Group M executed a note to petitioner for
$110,000; (5) on August 1, 1988, Mr. Bell assigned petitioner's
promissory notes to Jaguar Holdings (which became Ihatsu
Fudosan); (6) on March 1, 1989, Group M borrowed $150,000 from
Ihatsu Fudosan to make the final payment on the Yakima property
and to maintain working capital; and (7) on November 1, 1991,
Chestnut Grove and Group M executed assumption of liabilities
agreements for the notes originally made by petitioner to Hansa
Finance. On the basis of those alleged facts, petitioners argue
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